Background
Compliance & Security

AML Policy

Last updated: January 8, 2026

1

Introduction

CryptoPay is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and controls designed to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

We maintain a zero-tolerance policy towards money laundering and terrorist financing. All employees, contractors, and business partners are required to comply with this policy and applicable AML laws.

2

Customer Due Diligence (CDD)

We conduct thorough customer due diligence to verify the identity of our customers and assess the risk associated with their activities. Our CDD procedures include:

Identity verification using government-issued identification documents
Address verification through utility bills or bank statements
Business verification for corporate customers, including beneficial ownership information
Ongoing monitoring of customer transactions and activities
Enhanced due diligence for high-risk customers or transactions
3

Transaction Monitoring

We employ automated and manual transaction monitoring systems to detect unusual or suspicious patterns. Our monitoring includes:

Large or unusual transaction amounts
Rapid movement of funds
Transactions with high-risk jurisdictions
Unusual transaction patterns or frequencies
Transactions inconsistent with customer profile
Structured transactions designed to avoid reporting thresholds
4

Suspicious Activity Reporting

When we identify suspicious activities, we are required by law to file Suspicious Activity Reports (SARs) with the appropriate regulatory authorities. We will:

Promptly investigate any suspicious transactions or activities
File SARs within the required timeframes
Maintain strict confidentiality regarding SAR filings
Not disclose to customers that a SAR has been filed
Cooperate fully with law enforcement and regulatory investigations
5

Sanctions Screening

We screen all customers and transactions against international sanctions lists, including those maintained by the United Nations, European Union, and United States Office of Foreign Assets Control (OFAC). We will not provide services to:

Individuals or entities on sanctions lists
Politically Exposed Persons (PEPs) without enhanced due diligence
Entities from high-risk jurisdictions without proper verification
Customers involved in prohibited activities
6

Record Keeping

We maintain comprehensive records of all customer identification documents, transaction records, and AML compliance activities. These records are retained for a minimum of five years as required by law and are made available to regulatory authorities upon request.

7

Training and Awareness

All employees receive regular AML training to ensure they understand their responsibilities and can identify potential suspicious activities. Our training program covers:

AML laws and regulations
Recognition of suspicious activities
Customer due diligence procedures
Transaction monitoring techniques
Reporting requirements
Sanctions compliance
8

Compliance Officer

We have designated a Compliance Officer responsible for overseeing our AML program, ensuring compliance with all applicable laws and regulations, and serving as the point of contact for regulatory inquiries.

9

Cooperation with Authorities

We fully cooperate with law enforcement agencies, regulatory authorities, and financial intelligence units in their efforts to combat money laundering and terrorist financing. We provide information and assistance as required by law while maintaining appropriate confidentiality.

10

Contact Information

For questions or concerns regarding our AML Policy, please contact our Compliance Officer:

@
Emailcompliance@CryptoPay.com
📍
Address1001 S Main St STE 500
Kalispell Montana 59901

CryptoPay is committed to maintaining the highest standards of compliance and preventing financial crime.